PTAB

IPR2014-00498

Intel Corp v. Zond LLC

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1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for Generating a Plasma
  • Brief Description: The ’142 patent discloses a method and apparatus for generating plasma for applications like sputtering. The invention is directed to first creating a "weakly-ionized plasma" to reduce the probability of electrical arcing, and then applying a high-power electrical pulse to transition it into a "strongly-ionized plasma" for efficient processing.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 41 over Mozgrin in view of Kudryavtsev

  • Prior Art Relied Upon: Mozgrin (a 1995 journal article on plasma discharge) and Kudryavtsev (a 1983 journal article on ionization relaxation in plasma).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mozgrin teaches a sputtering apparatus that operates in distinct plasma regimes, corresponding to the claimed "weakly-ionized" and "strongly-ionized" plasmas. Mozgrin’s initial "pre-ionization" stage (region 1) creates a lower-density plasma that Petitioner mapped to the claimed "weakly-ionized plasma," asserting it reduces the probability of arcing. Mozgrin then applies a high-voltage pulse to create a "high-current magnetron discharge" (region 2), a higher-density plasma useful for sputtering, which Petitioner mapped to the claimed "strongly-ionized plasma." Kudryavtsev was cited to explain the underlying physics of how applying an electric field excites atoms and leads to multi-step ionization, which generates the strongly-ionized plasma.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine these references because Mozgrin explicitly cited Kudryavtsev's work when designing its experimental setup. A POSITA reading Mozgrin would therefore consult Kudryavtsev to better understand the ionization dynamics, particularly the generation of excited atoms and the subsequent rapid increase in plasma density ("explosive increase") that occurs when applying a voltage pulse.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because applying Kudryavtsev’s known principles of ionization physics to Mozgrin's disclosed system would predictably explain and optimize the transition from a pre-ionized state to a high-density sputtering state.

Ground 2: Obviousness of Claim 41 over Wang in view of Kudryavtsev

  • Prior Art Relied Upon: Wang (Patent 6,413,382) and Kudryavtsev.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Wang, like the ’142 patent, discloses a pulsed magnetron sputtering device designed to avoid arcing. Wang teaches applying a low "background power" level to sustain a plasma between pulses, which Petitioner mapped to the "weakly-ionized plasma." Wang then applies a high-power pulse to increase plasma density for efficient sputtering, which was mapped to the "strongly-ionized plasma." Petitioner argued Wang’s use of a sustained, low-power plasma explicitly teaches reducing the probability of breakdown. The teachings of Kudryavtsev were again used to explain the atomic excitation and multi-step ionization that occurs upon applying Wang's high-power pulse.
    • Motivation to Combine: Petitioner argued a POSITA would combine Wang and Kudryavtsev because Wang describes a pulsed system that suddenly applies an electric field to a weakly ionized gas. Kudryavtsev directly addresses the physics of this exact scenario. A POSITA would therefore look to Kudryavtsev to understand and optimize the performance of Wang’s system, specifically to achieve the rapid, "explosive" increase in plasma density that Kudryavtsev describes.
    • Expectation of Success: A POSITA would expect success in applying Kudryavtsev's teachings to Wang, as it would predictably lead to increased plasma density and a higher sputtering rate, which are desired outcomes in the field.

Ground 3: Obviousness of Claim 40 over Mozgrin in view of Lantsman

  • Prior Art Relied Upon: Mozgrin and Lantsman (Patent 6,190,512).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses claim 40, which includes a "means for diffusing the strongly-ionized plasma with additional feed gas." Petitioner again relied on Mozgrin for teaching the core two-stage (weakly-ionized to strongly-ionized) plasma generation process. Petitioner then argued that Lantsman teaches the missing "diffusing" element by disclosing a system where feed gas is continuously supplied throughout the entire plasma process (both pre-ignition and deposition phases) to maintain a stable operating environment.
    • Motivation to Combine: Petitioner contended a POSITA would combine Mozgrin and Lantsman to improve the stability and performance of Mozgrin's sputtering system. Both references are directed to sputtering, use two-stage power application, and are concerned with avoiding arcing. A POSITA would find it obvious to incorporate Lantsman’s conventional technique for continuous gas flow into Mozgrin’s system to maintain a constant pressure, balancing gas withdrawn by the vacuum pump.
    • Expectation of Success: The combination was presented as a predictable integration of known elements, where adding a standard gas flow system (Lantsman) to a plasma chamber (Mozgrin) would predictably result in a stable operating pressure without altering the fundamental plasma generation process.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 40 based on the combination of Wang and Lantsman, relying on a similar motivation to add continuous gas flow to Wang's sputtering system.

4. Key Claim Construction Positions

  • Petitioner proposed constructions for several key terms, arguing they should be given their broadest reasonable interpretation.
  • "weakly-ionized plasma" / "strongly-ionized plasma": Petitioner argued these terms are defined relative to each other based on density. "Weakly-ionized plasma" was construed as "a lower density plasma," and "strongly-ionized plasma" was construed as "a higher density plasma." This construction was central to mapping the prior art's lower-power/pre-ionization phases to "weakly-ionized" and higher-power/main discharge phases to "strongly-ionized."
  • "means for...": Petitioner identified corresponding structures in the ’142 patent for the various means-plus-function limitations in claims 40 and 41. For example, the "means for ionizing" was identified as a power supply coupled to a cathode/anode arrangement, and the "means for diffusing" in claim 40 was identified as feed gas lines.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 40 and 41 of the ’142 patent as unpatentable under 35 U.S.C. §103.